REACH Article 33 substance declarations

In June 2018 the number of substances of very high concern (SVHC) on the REACH Candidate List Substances increased to 191. Article 33 of the REACH Regulation requires companies who supply products which include any article which contains more than 0.1% by weight of any REACH Candidate List Substance to provide their customers with “sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance.” To assist companies to manage their regulatory burden, BOMcheck has published a screening for the electrotechnical industry which reduces the time and cost for REACH compliance by 61%.

The European Chemicals Agency (ECHA) “Guidance on Requirements for Substances in Articles” contains several recommendations for companies to use industry sector knowledge to assess which REACH Candidate List substances to expect in certain types of parts and materials and which substances can be ruled out of being present. The ECHA guidance states that supply chain communication is the most important way of gathering information about REACH Candidate List substances and recommends that industry should establish communication standards and systems.

The BOMcheck standardized materials declaration system works with the IEC 62476 materials declaration standard to implement these ECHA recommendations for the electrotechnical industry. BOMcheck has published a REACH Candidate List screening to help companies to save time and reduce costs for REACH compliance by screening out 102 substances which are not normally found in parts and materials in the electrotechnical industry. Companies in the electrotechnical industry can use this screening to reduce the number of REACH Candidate List substances that they need to investigate from 191 down to 89.

The BOMcheck regulatory compliance declaration tool builds on this screening and provides detailed chemicals guidance for each REACH Candidate List substance. The guidance shows that 14 of the remaining 89 substances are only found in exotic materials and components, which means that the regulatory compliance burden at most suppliers is reduced by 61%.

Suppliers can rely on the chemicals guidance to identify materials and parts which are at risk of containing some of the 89 substances used in the electrotechnical industry. If the guidance indicates that the supplier’s materials and parts are not at risk of containing a particular REACH Candidate List substance (for example, because the substance is used in PVDF plastic and the parts do not contain this type of plastic) then the supplier can claim compliance without additional efforts. The guidance helps the supplier to investigate substances which may be present in their parts and materials by providing information on known uses, typical addition rates and common trade names.

Saving time and reducing costs for REACH compliance has become even more important since the European Court of Justice ruling published 10 September 2015. The ruling imposes new duties on successive companies all along the supply chain to provide information on REACH Candidate List substances in individual component articles. In particular, the producer of the finished product is required to inform their customer if any component article in the product contains a REACH Candidate List substance in a concentration > 0.1% w/w of the component article.


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